ARRCS and Applicability Deep Dive

ARRCS (NJAC 7:26C) is the administrative requirements addressing the obligations of PRCRs for complying with the laws, regulations, and guidance for remediating contaminated sites.

This regulation instructs the Persons Responsible for Conducting Remediation (PRCR) as to their obligations during the entire course of remediation and, as is appropriate, the penalties for non-compliance may lead to fines, consent orders, or directives imposed by the NJDEP. However, in the NJ Site Remediation Professional Licensing Board (SRPLB) regulations (NJAC 7:26I), the Licensed Site Remediation Professional (LSRP) is required to instruct their clients about the stipulations and obligations involved in the overall remediation process.

If these requirements are not met it could result in actions by the SRPLB against the LSRP. Timeframes, notifications, and whistleblowing by the LSRP need to be understood by the PRCR. These need to be addressed in an “onboarding” meeting with your client at the onset of your relationship!